What are the income tax consequences to me of the Arrangement?
A Shareholder resident in Canada will generally realize a capital gain (or sustain a capital loss) on the disposition of the Shareholders Common Shares equal to the amount by which the total of the fair market value of the REIT Units received by the Shareholder exceeds (or is exceeded by) the adjusted cost base of the Shareholders Common Shares, net of any reasonable costs of making the disposition. One-half of any such capital gain must be included in income and one-half of any such capital loss may be utilized to offset taxable capital gains in accordance with the provisions of the Income Tax Act (Canada). The transactions under the Acquisition and the Arrangement will generally not give rise to any tax being payable under the Income Tax Act (Canada) by Shareholders (other than Dissenting Shareholders) who are nonresidents. The U.S. federal income tax consequences of the transactions comprising the Acquisition and Arrangement are not certain. If they constitute a tax-free reorganizat
